Date: May 31, 2013

IssueAccounting and Auditing

To: Financial Accounting Standards Board and International Accounting Standards Board

Filing Type: Regulatory

Description:  Letter in support for the convergence projects and to express our core thinking regarding FASB Financial Instruments Credit Losses (Subtopic 825-15) and IASB ED/2013/3 Financial Instruments Expected Credit Losses (the “Proposals”). In this letter we have outlined our thoughts, concepts, and objectives that the Financial Accounting Standards Board (“FASB”) and International Accounting Standards Board (“IASB”) can use in developing an accounting standard to recognize credit losses.

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